Infusion Providers Alliance

The Infusion Providers Alliance is the leading voice for in-office and freestanding ambulatory facility providers of drug infusion services. Alliance members are committed to preserving the integrity of the provider-patient relationship in a manner that delivers exceptional care to patients at a value to the health care system.

Our members have facilities located in communities across the nation, each of which offers a more convenient, more efficient and less expensive alternative for patients than receiving their infusions in the hospital setting. These facilities serve as critical access points of care for patients and save tremendous dollars for commercial and government payers alike while also lowering out of pocket costs for beneficiaries.

The Infusion Providers Alliance mission is to serve as a thought leader and to educate on issues critical to safeguarding, supporting, and strengthening provider directed, patient-focused access to in-office and freestanding ambulatory facility infusion services.

Coupon Provision

The Infusion Providers Alliance supports the Senate Finance Committee’s overall goals of lowering prescription drug costs for patients. However, the alliance is concerned that a coupon provision included in “The Prescription Drug Pricing Reduction Act of 2019” could increase out-of-pocket costs and make treatment less accessible, particularly for those with chronic diseases like Crohn’s and ulcerative colitis.

The coupon provision (SEC. 102 of the latest iteration of the bill) would include the value of coupons or patient assistance provided by manufacturers to patients that have commercial insurance policies as if it were part of the negotiated price of the drug for determining the calculation of average sales price (ASP) related to Medicare reimbursement. As a result, drug manufacturers are likely to curtail or eliminate their patient assistance programs, which would have a devastating impact on patient access and adherence to critical medications.

With patients facing increased cost-sharing imposed by insurance companies and PBMs, these coupon assistance programs have become increasingly important in helping many patients continue with expensive treatments. According to a 2018 study in Health Affairs, coupons typically save patients between $50 and $100 a month. (1) If pharmaceutical companies decide to reduce or terminate patient assistant programs, it could lead to reduced access to these essential medications for many patients who suffer from chronic conditions.

The provision also hinders the ability to provide certain drugs to Medicare beneficiaries in the convenience of medical offices because their Medicare ASP reimbursement would decline but their acquisition costs would not. Some practices may no longer be able to prescribe Part B drugs for Medicare patients, leading them to send patients to the less convenient and more expensive hospital setting and access in rural and other underserved communities would be placed at risk.

The bottom line is that the coupon provision in Sec. 102 in the Senate Finance bill could result in increased out-of-pocket costs and make treatments less accessible to patients. We urge the Senate to remove this provision before finalizing any drug pricing legislation. This provision was not included in any House bill.

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  1. 2018. https://www.healthaffairs.org/do/10.1377/hblog20180215.988517/full/